Tax thought leadership roundup (Winter 2017)

Keep up with the latest thinking on tax from CPAs in Canada with our roundup of new tax-related alerts, articles, guides, apps and thought leadership releases.

Issue in focus

Can fed’s tax expenditure review yield much-needed tax simplification? (CPA Canada)

With Finance Canada conducting an internal review of tax expenditures — and the Commons Finance Committee doing its own examination of the tax system — could Canadians’ longstanding desire for a simpler tax system become a reality?

General interest

Cameco: Landmark transfer pricing case begins (Richter LLP)

With $2.2 billion in estimated taxes at stake, a hearing before the tax courts is shaping up to be a landmark case in transfer pricing.

House of Commons Standing Committee on Finance targets tax avoidance and evasion (PwC)

With $444 million earmarked by the federal government in its 2016 federal budget for Canada Revenue Agency (CRA) to “crack down on tax evasion and combat tax avoidance,” hopes are high that the CRA can deliver. A House of Commons Standing Committee on Finance report makes 14 recommendations on how to achieve those goals.

Year-end tax planning for 2016 and early 2017

2016 Year-end tax planning guide (Grant Thornton)

Grant Thornton outlines multiple tax-saving measures that individual and business taxpayers might apply to their own tax situation before year end or early in 2017 to capitalize on opportunities and reduce their tax payable.

2016 Year-end personal tax planning tips (KPMG)

Key changes to the personal tax planning landscape, including a new top federal tax rate of 33 per cent, went into effect in 2016. KPMG provides a checklist and schedule of deadlines for 2016 and early 2017 to highlight what opportunities are available so you don’t miss out.

Owner-managers —Tax planning tips for 2016 (KPMG)

The end of the calendar year and first few months of the new year present a good opportunity for owner-managers to consider ways to improve their tax position.

Year-end tax planner: Helping individuals and owner-managed businesses save tax (PwC)

PwC’s year-end planner summarizes rates and new developments in 2016 and provides year-end tax planning checklists for owners, employees, the self-employed, investors and other individuals at various stages in their lifecycle.

Corporate tax

CRA treats certain U.S. partnerships as corporations (EY Canada)

The Canada Revenue Agency says it will consider limited liability partnerships and limited liability limited partnerships established under Delaware and Florida law to be corporations for Canadian income tax purposes. What are the tax implications for these partnerships in Canada?

Changes to the eligible capital property regime and their impact on farming business (BDO)

Significant changes to Canada’s eligible capital property regime will become effective on January 1, 2017. BDO Canada discusses the tax impact of these changes on farming corporations and potential planning opportunities.

Personal tax

Tax alert – Changes to the principal residence exemption announced (BDO)

BDO Canada’s Tax Alert captures key changes recently proposed by Finance Minister Bill Morneau, as the federal government attempts to crack down on potential violations of the principal residence exemption.

Indirect tax

Release of GST/HST proposals and consultation paper (Deloitte)

Deloitte summarizes key GST/HST legislative and regulatory proposals released by the Department of Finance in the summer of 2016, including proposed changes to private equity investment limited partnerships, relief for pension plan structures with a master pension entity, and amendments to a trust governed by a self-directed tax-assisted savings plan.

Watch out credit unions — Sales tax rules are evolving (MNP)

Canadian credit unions are starting to cross traditional provincial borders, which means that the federal Department of Finance has evolved its business model around how the GST/HST will apply to them. A key tax implication affecting all credit unions is whether they are considered “selected listed financial institutions.


U.S. and international tax

Final U.S. related-party debt regulations will impact U.S. subsidiaries of Canadian parent companies (Grant Thornton)

The U.S. Treasury Department and Internal Revenue Service recently released new regulations addressing the treatment of related-party debt. Grant Thornton documents the intention behind these regulations and sorts through their impact on U.S. subsidiaries of Canadian parent companies.

Foreign employers with non-resident employees working in Canada: Update on employer certification (EY Canada)

The Canada Revenue Agency has commenced audit activity for employer certification forms (RC473). EY highlights what foreign employers with employees working in Canada need to know and do to comply with their Canadian withholding and tax reporting obligations.

New international tax legislation (Deloitte)

The Department of Finance’s important new package of international draft tax legislation may require taxpayers to amend tax returns from prior years or evaluate whether to file certain elections before the end of 2016.

Post-election U.S. tax outlook (Grant Thornton)

Donald Trump will be sworn into office as the United States’ 45th president on January 20, 2017. Grant Thornton examines the potentially substantive impact of Trump’s proposed tax plan on U.S. taxpayers, including Canadian residents who must file tax returns with the U.S. Internal Revenue Service.

Tax consequences for Canadians doing business in the U.S. (BDO)

A Canadian business that has expanded into the United States, or has dealings with U.S. customers, faces potential U.S. tax liability and filing requirements, with steep penalties for non-compliance.

Accounting firms: Tax pages

Tax apps

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